- LEGAL INFORMATION
1.1 Learnsible Pte. Ltd. (Company Registration No.: 201942552Z), accessible from https://www.learnsible.com/ (“the Platform”), is a company incorporated in Singapore. (“Learnsible”, “we”, “our” or “us”).
- COLLECTION OF PERSONAL DATA
2.1 Personal data refers to data about an individual who can be identified from either (a) that particular data, or (b) from that particular data and other information which Learnsible has, or is likely to have, access to. Such personal data shall also refer to (i) data already in our possession; or (ii) the data to be collected by us.
Commonly collected personal data of our Users may include (but is not limited to):
- personal particulars (e.g. name, contact details, residential address, date of birth, identity card details, passport details, and/or education details);
- financial details (e.g. income, expenses, and/or credit history);
- banking information (e.g. bank account numbers);
- payment information (e.g. credit card number and related account and billing information);
- images and voice recordings of our conversations with you;
- employment details (e.g. occupation, directorships and other positions held, and/or employment history);
- tax and insurance information;
- information about your knowledge and experience, interests;
- communications between you and other Users, made through the Platform; and/or
- personal opinions made known to us (e.g. feedback or responses to surveys).
2.2 Collection of personal data
Wherever possible, we only collect personal data directly from you. Situations where this can occur include when (or before) you:
- register for an account with us;
- sign up for our newsletter and other mailings;
- use the Platform; and/or
- submit, post or upload any User-Generated Content.
2.3.2 In addition to personal data provided to us, we may also collect information related to you that is not considered personal data. We collect this information to improve the Platform. Such non-personal data includes information such as your IP address, the internet browser and operating system you use, details of your interaction with the Platform, and preferences. We use this information to improve the Platform, perform routine Platform maintenance, to generate aggregate Platform traffic reports, and enhance the performance of our Platform on different browsers and devices.
2.3.3 We may also receive personal information about you from other sources if you have given permission for that information to be shared. This may include information from commercially available sources, such as public databases and data aggregators, and information from third parties.
- USE OF PERSONAL DATA
3.1 Using your personal data
3.1.1 We collect personal data from our existing and prospective Users for various reasons. These purposes include:-
- fulfilling our obligations or exercising our rights under the General Terms and Conditions;
- providing and improving your experience on the Platform;
- authenticating your access to parts of the Platform you are authorised to access;
- reviewing, processing and confirming any request, application or User-content which you submit, in using the Platform;
- analysing the effectiveness of our advertisements, competitions and promotions;
- customising your Platform experience, as well as evaluating statistics on Platform activity, such as what time you visited it, whether you have visited it before, and what site referred you to it;
- making the Platform easier to use and tailoring the Platform to your interests and needs;
- marketing and communicating with you in relation to the Platform and our relevant service partners;
- processing, managing and administering accounts on the Platform;
- sending you information you have requested;
- responding to your comments, feedback or queries;
- resolving disputes, collecting fees, distributing returns, troubleshooting problems;
- fulfilling a legal or regulatory requirement;
- detecting, preventing or otherwise addressing fraud or security issues;
- informing you of any changes to our General Terms and Conditions;
- improving the quality of the Platform, its Content and functionalities with market research and surveys;
- supplying you with information that is relevant to your existing relationship with us; and
- suggesting products or services which we think may interest you.
3.1.2 Personal data will be held for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. We shall cease to retain personal data, or remove the means by which the personal data can be associated with particular individuals, as soon as it is reasonable to assume that (a) the purpose for which that personal data was collected is no longer being served by retaining it; and (b) retention is no longer necessary for legal or business purposes.
3.2 Sharing your personal data
3.2.1 Learnsible shares your personal information with trusted third parties and strategic partners. These parties and partners assist us with our business operations or provide the Platform. We may also share your personal data with trusted third parties and strategic partners that help Learnsible market to Users and potential Users. Such parties may either be in Singapore or abroad and may include:
- any member in our Group;
- our advertising, marketing and promotional agencies to help us deliver and analyse the effectiveness of our advertising campaigns and promotions;
- third parties for the purpose of raising funds;
- law enforcement or government authorities following due legal process in requesting disclosure of your information;
- third parties who wish to send you information about their products and services, but only if you have given us your consent to do so;
- third party providers of services, such as data processing; and
- web analytics tool providers, such as Google.
3.2.2 We may also share your personal data for the following reasons: –
- reasons provided under clause 3.1 ‘using your personal data’;
- verification of your identity;
- to protect our rights or property (including but not limited to any intellectual property rights);
- to respond to claims that you violated the rights of third parties;
- to conduct investigations into possible breaches of applicable laws; and/or
- to comply with a court order or other legal or regulatory requirements in the jurisdictions we operate.
3.2.3 In situations where a third party under contract with Learnsible collects personal data about you, we use commercially reasonable efforts to require the third party to exercise reasonable care in protecting your information.
- governmental authorities;
- private investigators;
- all the rightful owner(s) or interest holder(s); and/or
- injured third parties in the investigat ion of any potential or ongoing criminal or civil wrongdoing.
3.2.6 Further, we may disclose your identity and contact information, or such other transaction-related data:
- if requested by a government or law enforcement body, private investigator, rightful owner or interest holder and/or any injured third party or as a result of a subpoena or other legal action; or
- if we are of the view, in our sole and absolute discretion, that it would be in our best interest to do so.
3.2.7 We shall not be liable in any way for damages or results arising from such disclosure, and you agree not to bring an action or claim against us for such disclosure.
- AMENDMENTS TO PERSONAL DATA / OPT OUT
4.1 You have a right to access, change and remove the personal data held by Learnsible. If you wish to do so, please contact our Data Protection Officer at firstname.lastname@example.org. You may also access, change and remove your personal details by clicking on ‘My Account’. You may also decline to receive e-mails by clicking on ‘unsubscribe’ in any marketing e-mail you receive.
To the extent not required by Learnsible in connection with providing the Platform, if you do not want your personal data to be shared among affiliates, business partners or unrelated third parties, you may opt-out of such information sharing by sending us an email at email@example.com
5.1 Learnsible uses reasonable measures to protect your personal data and to store it securely. Where personal information is entered on the Platform, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) technology. However, due to the inherent nature of the Internet as an open global communications vehicle, no method of transmission over the Internet or method of electronic storage is 100% secure. While security cannot be guaranteed, we strive to protect your personal data and are constantly reviewing and enhancing our security protocols to ensure that your personal data is not subject to unnecessary risks.
- TRANSFER OF PERSONAL DATA
6.1 We may transfer, store, process and/or deal with your personal data outside Singapore. In doing so, we will comply with the PDPA and other applicable data protection and privacy laws.
6.2 Learnsible, or substantially all of Learnsible’s assets, or effective control over them, may be acquired by one or more third parties as a result of an acquisition, merger, sale, reorganisation, consolidation or liquidation. In such a situation, databases containing User personal information may be one of the assets transferred, over which such third parties may gain control, or to which they may gain access. In using the Platform, you consent to such transfer of, control over and access to your personal data.
- CONTACTING YOU
7.1 Learnsible is committed to complying with the Do Not Call (“DNC”) provisions set out in the PDPA. If you have registered your telephone number with the DNC Registry, Learnsible will not send you promotional and marketing messages via phone calls, text messages and faxes. However, if you have previously given Learnsible consent to contact you for such purposes, we will continue to do so until you withdraw your consent.
7.2 If you no longer wish to receive marketing and/or promotional messages from Learnsible and had previously provided Learnsible with your consent to do so, you can withdraw your consent by contacting us at firstname.lastname@example.org.